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Wynne Construction Data Protection Policy

1. Policy Statement

During the course of our activities it is necessary for us to collect, store and process personal information about our employees, clients, suppliers and subcontractors and other parties such as job applicants and work experience students.

Here at Wynne Construction (the trading name of C Wynne & Sons Ltd) we have always taken data protection and the security of personal information very seriously.

We respect and value the privacy of all our employees, clients, suppliers and subcontractors and other parties and will only collect and use their personal data in ways that are described here, and which are consistent with our obligations and their rights under the law.

Data users are obliged to comply with this policy when processing personal data on behalf of Wynne Construction. Any breach of this policy will be taken seriously and may result in disciplinary action. Under Data Protection laws in the UK, certain mishandling of personal data is deemed a criminal offence and can lead to substantial fines.


2. About the Policy

The types of personal data that we (Wynne Construction) may be required to handle include information about past, current and prospective employees, clients, subcontractors, suppliers and other parties. The personal data, which may be held electronically or in hard copy, is subject to certain legal safeguards specified in the Data Protection Legislation.

This policy and any other documents referred to in it sets out the basis on which we will process any personal data we collect from data subjects, or that is provided to us by data subjects or other sources.

This policy does not form part of any employee's contract of employment and may be amended any time.

This policy sets out rules on Data Protection and the legal conditions that must be satisfied when we obtain, handle, transfer, store and/or use personal data.

We will provide relevant staff with training about privacy to support compliance with this policy.

We will develop, maintain, and publish procedures, guidance and standards to assist achievement of compliance with this policy.

If you have any queries in relation to this policy or how to apply it, you should contact the Data Protection Administrator. The Data Protection Administrator for Wynne Construction is Val White: Tel 01745 586666 or email: gdpr@wynneconstruction.co.uk

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3. Definitions of Data Protection Terms

Data is information which is held electronically, or in physical filing systems.

Data subjects for the purpose of this policy include all individuals about whom we collect/hold personal data. All data subjects have legal rights in relation to their personal data.

Personal data means data relating to a living individual who can be identified from that data (or from that data and other information in our possession). Personal data can be factual (such as a name, address or date of birth) or it can be an opinion about that person, their actions and behaviour. Personal data does not need to contain the name of an individual to be classified as personal data. The use of a unique identification number (such as an employee number), location data, or an online identifier (such as an IP address) may, in some circumstances, be sufficient to identify an individual.

Data controllers are the people or organisations that determine the purpose(s) for which, and the manner in which, any personal data is processed. They are responsible for establishing practices and policies that meet the Data Protection Legislation requirements.

Data processors include any person or organisation that processes personal data on the instruction of a data controller. Employees of data controllers are excluded from this definition but it could include suppliers who handle personal data on Wynne Construction's behalf.

Data users are Wynne Construction employees whose work involves processing personal data. Data users must protect the data they handle in accordance with this policy and any applicable data security procedures at all times.

Processing is any activity that involves use of the data. It includes obtaining, recording holding, organising, amending, retrieving, using, disclosing, erasing, or destroying data. Processing also includes transferring personal data to third parties.

Sensitive Personal Data includes information about a person's racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, the use of genetic data or biometric data for the purpose of uniquely identifying individual, physical or mental health or condition or sexual life or sexual orientation, or about the commission of, or proceedings for, any offence committed or alleged to have been committed by that person, the disposal of such proceedings or the sentence of any court in such proceedings. Sensitive personal data can only be processed under strict conditions, including a condition requiring the express consent of the person concerned.

Data Protection Legislation refers to any current or future laws or directives that are or will be applicable in the UK with respect to data processing.

Service Provider means any third-party company that provides services to Wynne Construction.

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4. Data Protection Principles

Anyone processing personal data must comply with the principles for processing personal data as contained within Data Protection Legislation. These provide that personal data must be:

(1) Processed fairly, lawfully and transparently;

(2) Processed for specified, explicit and legitimate purposes and processed in a manner consistent with those explicit purposes;

(3) Adequate, relevant and limited to the purpose;

(4) Accurate;

(5) Not kept longer than necessary for the purpose;

(6) Processed securely:

(7) Not transferred to countries outside of the European Economic Area (EEA) without an adequate level of protection for the rights and freedoms of data subjects being assured by that country or territory.

Personal data must be processed in a manner that will enable Wynne Construction to demonstrate accountability in meeting each of the above principles.

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5. Fair, lawful and transparent processing

Data Protection Legislation is not intended to prevent the processing of personal data, but to ensure that it is done fairly, in a transparent manner and without adversely affecting the rights of the data subject. Data processing must be done in line with data subjects' rights under the Data Protection Legislation.

For personal data to be processed lawfully, it must be processed on the basis of one of the legal grounds set out in the Data Protection Legislation. These include:

The data subject's consent to the processing for one or more specific purposes which are made clear to the data subject or

That the processing is necessary for:

The performance of a contract with the data subject (for example an employment contract or a contract for the provision of services);

For the compliance with a legal obligation to which the data controller is subject; or

For the legitimate interest of the data controller or another party to whom the data is disclosed (where legitimate interest has been specifically identified and advised to a data subject) and where the processing of data for this legitimate interest does not seriously impact on the interests or fundamental rights of data subjects.

When sensitive personal data is required to be processed, additional conditions to those set out above must also be met. If you are intending to process sensitive personal data, please contact the Data Protection Administrator.

The Data Protection Legislation establishes a requirement to be transparent with the data subject. Where we collect personal data directly from data subjects, we will inform them about the purpose(s) for which we intend to process the personal data, the legal basis upon which the processing is reliant (for example consent or a legitimate business interest), details about where the personal data is stored, the types of third parties the personal data will be shared with (if any), the period of time the personal data will be stored for, and their rights.

If we receive personal data about a data subject from other sources, we will provide the data subject with this information as soon as possible thereafter, but always within one month of having collected the personal data.

We will normally only process sensitive personal data if the data subject has explicitly consented to its processing or there is a legal or regulatory obligation for us to do so. We may also process sensitive personal data where this is necessary for the purposes of equal opportunity and diversity monitoring provided this is carried out with appropriate safeguards for the individual(s) concerned.

When processing personal data as data controllers in the course of our business, it is important that we ensure that we have met the above requirements as a breach could result in severe penalties.

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6. Processing for specified, explicit and legitimate purposes

In the course of our business, we may collect and process personal data that is received directly from a data subject or from other sources. We will only process personal data for legitimate regulatory, client service or business purposes or for any other purposes specifically permitted by the Data Protection Legislation. We will notify those purposes to the data subject when we first collect the data or as soon as possible thereafter.

Personal data may only be processed for the purpose for which it was originally collected. Processing for another purpose to that which was originally specified requires approval from your Data Protection Administrator who In considering the use of the personal data for another purpose, should have due regard for whether it is connected with the original purpose, the context in which the personal data was collected, whether it relates to sensitive data and the potential impact on a data subject. Where we process personal data for a different purpose than for which it was originally collected, we must notify the data subject(s).

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7. Adequate, relevant and limited to the purpose

We will only collect personal data to the extent that it is required for the specific purposes notified to the data subject. You must consider whether the personal data you are requesting a data subject to provide is necessary with a view to minimising the personal data we collect. Furthermore, the personal data should only be accessible by those who need to know, see or process that personal data.

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8. Accurate data

We will ensure that personal data we hold is accurate and kept up to date. We will check the accuracy of any personal data at the point of collection and at regular intervals thereafter. We will take all reasonable steps to destroy or amend inaccurate or out-of-date data.

Staff must notify HR immediately of any changes to their personal circumstances.

If requested by a data subject to update, rectify or correct any of that data subject's personal data, that request should be actioned as soon as reasonably practicable, and we should also ensure that any service provider we use to process personal data, is informed of the request so that they too can update their records.

In the event that we consider that a request to correct 'inaccurate data' is wrong, we should advise the data subject of this as soon as reasonably practicable. Any course of action taken must be recorded appropriately.

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9. Data retention

We will not keep personal data longer than is necessary for the purpose or purposes for which it was collected. Reference should be made to the Wynne Construction's Document Retention policy. We will take all reasonable steps to destroy or erase from our systems, all data which is no longer required.

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10. Data security

Wynne Construction operates a range of controls to secure personal information against unlawful or unauthorised processing and against the accidental loss of or damage to, personal data.

We will put in place procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction. Personal data will only be transferred to a data processor if they agree to comply with those procedures or policies, or if they put in place adequate measures which are equal to,or of a higher standard, than those of Wynne Construction.

We will maintain data security by protecting the confidentiality, integrity and access of personal data, defined as follows:

(a) Confidentiality means that only people who are authorised to use the data can access it.

(b) Integrity means the security of the personal data must be effective.

(c) Access means that only authorised users (being those who need access to the personal data for a justifiable business reason) should be able to access the data.

Security procedures include:

(a) Entry controls: Entry to Wynne Construction's offices is by coded entry.

(b) Secure lockable physical storage: Cupboards/rooms are to be kept locked if they hold confidential information of any kind. (Personal information is always considered confidential.)

(c) Electronic storage: All data is stored on our server and backed up to the cloud. Access to this information has a strict access protocol.

(d) Methods of disposal: Paper documents are to be shredded immediately and electronic storage devices should be appropriately wiped when they are no longer required.

(e) Equipment: Data users must not leave confidential information on show on their desks when unattended and should lock their computer if moving away from their desks.

Employees who receive emails on their phones or who use laptops for work purposes must ensure that their phones and laptops are password protected.

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11. Data subject's rights under Data Protection Legislation

We will process all personal data in line with data subjects' rights, in particular their right to:

(a) Request access to any data held about them by a data controller (see also clause 14)

(b) Prevent the processing of their data for direct marketing purposes

(c) Ask to have inaccurate data amended (see also clause 8)

(d) Object to the processing of their personal data in certain instances

(e) Withdraw their consent in the case where consent had previously been granted

Furthermore, we must assess our processing steps where such processing could cause damage or distress and address this appropriately.

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12. Disclosure and sharing of personal information

Personal data may only be shared with authorised Wynne Construction personnel.

We may also disclose personal data we hold to third parties:

(a) In the event that we buy or sell any business or assets, in which case we may disclose personal data we hold to the prospective buyer or seller of such business or assets.

(b) If our, or substantially all of our assets, are acquired by a third party, in which case personal data we hold will be one of the transferred assets.

We may disclose or share personal data if we are under a duty to comply with any legal obligation, or in order to enforce or apply any contract with the data subject or other agreements; or to protect our rights, property or safety of our employees, customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

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13. Internal personal data processing

Wynne Construction processes personal data relating to its employees and certain employees of service providers. Data users who process personal data on behalf of Wynne Construction must process that data in a manner consistent with all relevant clauses in this policy and other applicable company policies and those data users are also reminded of their responsibility to maintain the standards contained within this policy as guardians of personal data.

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14. Dealing with subject access requests

Data subjects must make a formal request in writing for information we hold about them. Employees who receive a written request for personal data from anyone (whether this is from another Wynne Construction employee, a service provider and/or customer) should forward it immediately to;

(a) HR if the request is from a current or former member of staff, and

(b) the Data Protection Administrator, if the request is from anyone else, for example a subcontractor.

There is a statutory time period for responding to such requests so it is important that any such request is dealt with promptly as soon as it is received. In responding to a request, where the data subject has not been specific in their request, we should request them to specify exactly what information they want access to. There is no fee for the information request, however, in cases where a request is unfounded or excessive (including repetitive requests), then a reasonable fee (based on the administrative cost) may be charged.

The relevant data controller that has received the request may refuse to provide certain personal data in response to a request from an individual where the Data Protection Legislation provides an exemption. There are very few exemptions for non-disclosure and the application of these exemptions requires careful consideration.

When receiving telephone enquiries, we will only disclose personal data if that request is followed up by a request in writing.

In each case where we are unclear of a requestor's identity, we must request that the data subject provides us with identification documents.

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15. Notifications to, and communications with, the Information Commissioner's Office (ICO)

The ICO maintains a public register of all data controllers registered to process personal data. The Data Protection Administrator is responsible for ensuring compliance with the requirement to manage and maintain company notifications made to the ICO.

Any correspondence, apart from that relating to the notification process received, from the ICO should be sent to the Data Protection Administrator as soon as possible upon receipt.

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16. Implementation, enforcement and reporting data privacy incidents

It is very important that we are able to deal with any data security incident as soon as possible to effectively manage the incident. As such, all employees must notify the Data Protection Administrator immediately after becoming aware of any data security incident. There is a 72-hour window in which such an incident has to be reported to the ICO.

A potential data breach is an incident in which sensitive, confidential or otherwise protected data has been accessed, disclosed or handled in a manner inconsistent with the intended treatment of that information. Examples can include unauthorised access of data, loss of data and inappropriate disclosure of data to a recipient.

We will require all service providers who process personal data on our behalf to promptly notify us of any potential data security breaches so that we are able to take appropriate action to address the matter.

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17. Queries/concerns

If you have any queries or concerns in relation to this Policy, please contact the Data Protection Administrator, Val White on Tel: 01745 586666 or email: gdpr@wynneconstruction.co.uk

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